Opinion
7382-22
06-29-2022
TONI E. SAMUEL & DION R. SAMUEL, SR., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Upon further review of the record in this case, the Court notes that the Petition, filed March 21, 2022, has not been properly executed, insofar as it has not been signed by petitioner Dion R. Samuel, Sr. or a practitioner admitted to practice before this Court, as required by the Tax Court Rules of Practice and Procedure.
However, on June 28, 2022, the parties filed a Stipulation of Settlement and a Proposed Stipulated Decision, resolving the underlying tax liability that is the subject of this proceeding. Insofar as the Court's procedures require a stipulated decision to bear the original signature of the taxpayer, provided at minimum to the filing party as a high-resolution digital image and so maintained by the filing party, Mr. Samuel's intentions to file and prosecute the case in this forum have been adequately verified. Moreover, the Court notes that Mr. Samuel has also signed the document that has been filed by the Court in this case as petitioners' Motion for Entry of Decision.
Upon due consideration of the foregoing, it is
ORDERED that, when the Stipulated Decision is entered in due course, the Petition in this case shall be deemed to have been ratified and affirmed by petitioner Dion R. Samuel, Sr.